RE: Letter to Kay Mann

Steve and Ben,

I received a current statement of the open matters we have with GT. In rough numbers it is around $270,000 for all the Florida work, excluding Ft. P. Most files only have one month worth of billing, so it gives us a bit of a feel for the order of magnitude of the burn rate. What I don't know is if the burn rate is increasing or decreasing. With the litigation, the moratorium and the DEP proceedings, an escalation wouldn't surprise me.

Unfortunately, we don't have an estimate yet on the whole package, including the moratorium ($80,000 bill for June) and the land use/environmental work ($44k in June for Deerfield, $71k for Pompano). I would like to get you a more comprehensive picture of what we can expect in the next couple of months.

Kay

-----Original Message-----
From: Krimsky, Steven
Sent: Wednesday, August 01, 2001 5:15 PM
To: Jacoby, Ben
Cc: Mann, Kay; Leigh, Lorie
Subject: FW: Letter to Kay Mann

Ben,

Attached are GT's views/scenarios regarding the Deerfield / Coconut Creek law suit. Bottom line - total estimated max cost ~$150k should a trial not be required and upwards to ~$250k+ should a full blown trial occur.

GT expects to have a timeline later in the week for the various scenarios.

Deerfield is planning to submit the motion to dismiss tomorrow, which is the 20 day deadline. The dismissal hearing is tentatively planned for August 14th. Deerfield wants Enron to intervene as soon as possible so as to be in a position to participate in the dismissal hearing.

Upon Enron's request to intervene, the judge typically requires 5 business days to set the intervention hearing. Working backwards, assuming the dismissal hearing is scheduled for the 14th, the intervention hearing should take place on the 13th at the latest, which will require an intervention request be filed no later than Monday the 6th.

GT is awaiting approval to proceed, and if possibly, would like to file the motion to intervene on Friday.

Lets talk tomorrow - I'll get Lorie to schedule a time.

Steve

-----Original Message-----
From: MedleyB@gtlaw.com@ENRON [mailto:IMCEANOTES-MedleyB+40gtlaw+2Ecom+40ENRON@ENRON.com]
Sent: Wednesday, August 01, 2001 3:46 PM
To: Krimsky, Steven
Subject: Letter to Kay Mann

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